Financial Crime Risk Management

Non-Executive Director ('NED') Support Services
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Interim Support

Commercial organisations typically engage Interim Management for a specific project, or when a need is identified for an experienced practitioner to fill a temporary skills gap in a management team. 

We have supported clients to fill temporary gaps in senior financial crime prevention roles, typically where there has been a sudden change in in-house capability, due to resignation, sickness or dismissal.

We have supported clients at Group and Global Policy level, and in UK FCA regulated firms, as interim Money Laundering Reporting Officer and Head of Financial Crime Prevention. 


Whether a start-up or established business, a firm may encounter difficulty recruiting to a senior position, possibly due to scarcity of skill-set in the market, an impending merger or acquisition or for other reason(s).

Where recruitment is protracted due to a candidate's notice period, or an organisational change means the Target Operating Model ('TOM') is not yet defined, we can help with temporary senior level support. 

We support clients with TOM build and implementation on financial crime risk. We provide functional support to deliver specific projects. These can be a few weeks duration or much longer in some cases.


Money laundering reporting function (SMF17) - The money laundering reporting function is the function of acting in the capacity of the money laundering reporting officer of a firm.

The FCA (Handbook SUP 10C.3.13R) enables cover to be given for emergencies. However, as soon as it becomes apparent that a person will be performing an FCA-designated SMF17 for more than 12 weeks, the firm should apply for approval.

The FCA can grant a time-limited approval where a firm needs to appoint a candidate on an interim basis while the firm seeks to appoint a permanent candidate. The FCA may approve the interim appointee on a time-limited basis.


Our Services
Project Delivery & Support

FCRM provides temporary provision of senior level financial crime risk management resource and skills. The short-term provision of project services by an experienced manager to support a period of organisational transition or change.

Useful links
FCA Handbook - SUP 10C.3.14
FCA Handbook - SUP 10C.12.7

Independent Professionals and the Self Employed

CIPD - Temporary and agency workers